Privacy Notice – Consumer surveys

Effective from: 2021-10-25

Published at: 2021-10-25

This document describes how Volvo Cars (as defined below) processes your personal data when you engage with one of our consumer surveys (hereinafter “Consumer Survey”).

You can find below:

This Privace Notice and its rights and obligations referenced herein are subject to the Argentinean Law.

1. Who we are

The entities that are jointly responsible for the processing of personal data in relation to the Consumer Surveys are EXIMAR INTL S.A., having it registered office at Carlos Pellegrini 961, 3rd Floor, City of Buenos Aires, Argentina, company registration number 24160, and tax identification number CUIT 30-71079356, and Volvo Car Corporation, having its registered office at Assar Gabrielssons Väg, 40531 Gothenburg, Sweden, company registration number 556074-3089 herein referred to as “Volvo Cars”, “we”, or “us”.

2. What personal data we collect and why

When you interact with our Consumer Survey, we will process the following categories of data about you:

Identifiers such as name, e-mail address , telephone number, salutation, age, gender, postal code, and city. We process this data in order to send the Consumer Survey and assess consumer performance by segmentation. The data is processed based on our legitimate interest to improve the business purpose and customer experience that your survey response concerns (Art.6(1)(f) GDPR).
Your Vehicle data such as vehicle type, Vehicle Identification Number (VIN), and registration number (REG). We process this data based on our legitimate interest to assess field action and warranty performance (Art.6(1)(f) GDPR).
Contract type, subscription number, vehicle relationship (contract/sales type starting and end date). We process this data in order to send the Consumer Survey and assess consumer performance by segmentation allowing us to improve the overall business operations and the consumer experience. The data is processed based on our legitimate interest to improve the business purpose and customer experience that your survey response concerns (Art.6(1)(f) GDPR).
Opening/clickthrough rates. We process this data for statistical analysis and range measurement, and to understand the interests of our consumers. For this analysis, the e-mail invites contain so-called web beacons or tracking pixels, which display single-pixel image files that are also embedded in our website, where we ask for your consent in order to deploy those. The data is processed based on our legitimate interest to understand overall survey performance and survey interaction (Art. 6(1)(f) GDPR).

The supply by you of your personal data is optional. Your objection to supply your personal data will be of no consequence whatsoever. You acknowledge that the personal data supplied by you is true and correct.

3. How long we keep your data

Your survey feedback responses will be kept up to five (5) years from the time you submit your response, after which time it will be anonymized.

In order to keep your responses secure, the invitation for feedback provides you with an individualised questionnaire that no other person can access. The survey platform and our data storage facilities have security measures in place to protect the loss, misuse, and alteration of the information under our control.

Only certain employees and Volvo Cars’ trusted processors (as detailed below in Section 4) have access to the personal information you provide us. They have access only for case handling, data analysis and quality control purposes.

4. Who we share your personal data with

We will share your personal data with the following categories of third parties, on a need-to-know basis:

Our processors supporting our activity in general, such as providers of IT solutions;
Our processors supporting delivering the Consumer Surveys, which are limited by contract in their ability to use your personal data for any purpose other than to provide services for us in compliance with each data processing agreement in place:
- Medallia, Inc. (EU, United States) – customer experience management.

Your personal data will be disclosed to and processed by your selected retailer (if applicable) and companies within the same group of companies as Volvo Cars.

As owner of your personal data, you expressly consent that such data may be transferred to any of the companies within the same group of companies as Volvo Cars in order to comply with the purposes directly related to the assignor and assignee’s lawful interest, especially to analyze the answers to Consumer Surveys and any significant business in connection with such data.

You further expressly consent to the transfer of personal data of any kind to any country or international or supranational bodies, even if they do not provide appropriate levels of protection.

5. Your rights in relation to the data processing we perform

Under the GDPR, you have specific legal rights relating to the personal data we process about you. These are briefly explained below, and you can exercise them by filling out the dedicated form indicated below.

Right to withdraw consent: Where you have given consent for the processing of your personal data, you may withdraw your consent at any moment with effect for the future.
Right to access your personal data: You may ask from us information regarding personal data that we hold about you. We will provide you with a copy of your personal data upon request. If you request further copies of your personal data, then we can charge you with a reasonable fee that we base on the administrative costs. You have the right to the information about our safeguards for the transfer of your personal data to a country that is outside the EU and the EEA if you request that we confirm whether or not we process your personal data, and we transfer your personal data to a country that is outside the EU and the EEA.
Right to rectification: You may obtain from us rectification of incorrect or incomplete personal data concerning you. We make reasonable efforts to keep personal data in our possession or control which are used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us.
Right to restriction: You may obtain from us restriction of processing of your personal data, if:
1. you contest the accuracy of your personal data, for the period we need to verify the accuracy,
2. the processing is unlawful and you request the restriction of processing rather than erasure of your personal data,
3. we do no longer need your personal data for the processing purpose but you require them for the establishment, exercise or defense of legal claims, or
4. you object to the processing while we verify whether our legitimate grounds override yours.
Right to portability: You have the right to receive your personal data that you have provided to us, and, where technically feasible, request that we transmit your personal data (that you have provided to us) to another organization, if:
1. we process your personal data by automated means;
2. we base the processing of your personal data on your consent, or our processing of your personal data are necessary for the execution or performance of a contract to which you are a party;
3. your personal data are provided to us by you; and
4. your right to portability does not adversely affect the rights and the freedoms of other persons.
You have the right to receive your personal data in a structured, commonly used and machine-readable format. Your right to receive your personal data must not adversely affect the rights and the freedoms of other persons. Your right to have your personal data transmitted from us to another organization is a right you have if such transmission is technically feasible.
Right to erasure: You have the right to request that we delete the personal data we process about you. We must comply with this request if we process your personal data, unless processing is necessary:
1. for exercising the right of freedom of expression and information;
2. for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject;
3. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
4. for the establishment, exercise or defense of legal claims.
Right to object: You may object – at any time – to the processing of your personal data due to your particular situation, provided that the processing is not based on your consent but on our legitimate interests or those of a third party. In this event we shall no longer process your personal data, unless we can demonstrate compelling legitimate grounds and an overriding interest for the processing or for the establishment, exercise or defense of legal claims. If you object to the processing, please specify whether you also wish the erasure of your personal data, otherwise we will only restrict it. You also have the right to object at any time, regardless of any reason, to the processing of your personal data for direct marketing (which includes profiling to the extent that it is related to such direct marketing), if such processing was based on our legitimate interest. If the marketing was based on your consent, you can withdraw consent (see above).
Right to lodge a complaint: You can lodge a complaint to your local data protection supervisory authority or with any other data protection authority in the EU. However, we will appreciate if you first contact us to try and solve your problem – you can find our contact details below.

You can exercise your rights in relation to us by filling out this form, which will help us to deal with your request properly. The online form contains the information that we need to verify your identity and review your request. For requests submitted by telephone or email, you will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal data we collected and describe your request in sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

You can exercise these rights in relation to all of the joint controllers mentioned in this notice.

THE NATIONAL DEPARTMENT FOR THE ACCESS TO PUBLIC INFORMATION OF THE ARGENTINE REPUBLIC (AGENCIA DE ACCESO A LA INFORMACIÓN PÚBLICA DE LA REPÚBLICA ARGENTINA), in its capacity as Supervising Authority Law No. 25326, has the power to address those complaints and claims filed by any person concerned related to any breach of the applicable rules governing the protection of personal data.

6. Contact information

In order to exercise your rights, please visit https://www.volvocars.com/ar/pie-de-pagina/privacidad. If you have any other questions regarding the subject matter of personal data protection, you can contact directly EXIMAR INTL S.A. at the contact details mentioned below.

Company: EXIMAR INTL S.A. Data Protection Officer as follows:

Postal address: Carlos Pellegrini 961, 3rd Floor, City of Buenos Aires, Argentina.

Email: volvo@eximar.com.ar

You can also contact the Volvo Car Corporation Data Protection Officer as follows:

Company: Volvo Car Corporation

Postal address: Volvo Car Corporation, Assar Gabrielssons Väg, SE-405 31 Gothenburg, Sweden

Email: globdpo@volvocars.com

7. Changes to our Privacy Notice

We reserve the right, at our discretion, to modify our privacy practices and update and make changes to this privacy notice at any time. For this reason, we encourage you to refer to this privacy notice on an ongoing basis. This privacy notice is current as of the date which appears at the top of the document. We will treat your personal data in a manner consistent with the privacy notice under which they were collected, unless we have your consent to treat them differently.